How to report interprofessional telephone/internet/electronic health record consultations

Psychologists have a mechanism to provide and report interprofessional telephone/internet/electronic health record consultations. In these consultations, psychologists and other providers may use phone, written, or internet communications to ask other health care professionals for advice in diagnosing and treating their patient’s condition. Face-to-face engagement with a patient is not required.

Effective in January 2025 the Centers for Medicare and Medicaid Services (CMS) finalized six new HCPCS codes (G0546–G0551) for the coverage of interprofessional consults “provided by a practitioner in a specialty whose covered services are limited by statute to services for the diagnosis of mental illness.” CMS specifically noted that these codes were created to expand its scope of covered behavioral health services and are intended for use by clinical psychologists, clinical social workers, mental health counselors, and marriage and family therapists because these practitioners cannot independently bill Medicare for E/M visits.

These new HCPCS codes mirror CPT® codes 99446–99449 and 99451–99452, which are to be used by practitioners who are eligible to independently bill E/M visits. However, in 2023, these codes were revised to include “other qualified health care professionals” in the code descriptors, guidelines, and instructional parenthetical language, where previously it had only specified “physician.”

When reporting interprofessional consultation services to Medicare, psychologists must use HCPCS codes G0546–G0551; however, some private or commercial insurers may not accept HCPCS codes, therefore, we strongly encourage all providers to contact all of your third-party payers prior to usage to confirm their policy regarding reporting HCPCS codes versus CPT codes 99446–99449, 99451, and 99452.

There is an unprecedented growing mental health crisis among all ages across the country. One in five adults experience a diagnosable mental health disorder and two out of five report symptoms of anxiety and depression (NAMI, June 2022). It is critical that those who struggle with mental health problems receive medically necessary care; however, less than half of those who need care are receiving the help they need. Timely access to mental and behavioral health services is often limited by resources, especially in rural and underserved, uninsured, and ethnically diverse patient populations.

Interprofessional consultation services offer several key benefits, including timely access to mental and behavioral specialty care, decreased need for in-person referral or visit, shortened wait times, and an opportunity to support providers in a team-based approach to care. Non-face-to-face consultations are a way to get patients rapid access to specialty psychology expertise that benefits both the patient and the provider.

Interprofessional telephone/internet/electronic health record consultations are assessment and management services in which “a patient’s treating (e.g., attending or primary) physician or other qualified health care professional (QHP) requests the opinion and/or treatment advice of a physician or other QHP with specific specialty expertise (the consultant) to assist in the diagnosis and/or management of the patient’s problem without patient face-to-face contact with the consultant” (2025 CPT Manual, p. 43).

Codes G0546–G0550, 99446–99451 are reported by consulting providers who communicate with, and provide expert advice to, treating providers regarding a diagnosis or management of a patient’s problem. These services do not include face-to-face interaction with the patient. Consultation services can be provided to either a new patient, or an established patient with a new problem or an exacerbation of an existing condition. Because the type and/or severity of the problem is not specifically defined, any condition may qualify for consultative services; however, the codes are typically reported when a patient presents with a new problem or when an existing condition is exacerbated or not well-managed. Conversely, codes G0551, 99452 are reported by the treating/requesting provider for the total time spent preparing records and the referral for the consulting clinician.

There are two types of interprofessional consultation services via communications technology.

Consultation Services with Discussion, Verbal and Written Report Required

(HCPCS/CPT codes G0546, G0547, G0548, G0549, 99446, 99447, 99448, 99449)

Psychologists can report HCPCS codes G0546–G0549 when billing Medicare or CPT codes 99446–99449 if more than half of total/cumulative service time is devoted to the consultative verbal or internet discussion with the treating/requesting provider. If greater than 50% of the time for the service is devoted to data review and/or analysis, CPT codes G0546–G0549 and 99446–99449 should not be reported. Additionally, the service concludes with the consulting psychologist providing both a verbal opinion report and a written report to the treating/requesting provider.

Consultation Services without Discussion, Only Written Report Required

(HCPCS/CPT code G0550, 99451)

Codes G0550 and 99451 are reported for the total time spent by the consulting psychologist to access data/information via the electronic health record (EHR), telephone, or internet, performing data review and/or analysis, and interprofessional communication. While a verbal opinion report is not a required component when reporting code G0550 when billing Medicare or code 99451 when billing some commercial insurers, the psychologist must provide a written report to the treating/requesting provider for inclusion in the patient record.

Record and Referral Preparation Services, performed by the treating/requesting provider

(HCPCS/CPT code G0551, 99452)

Different from the previously mentioned services, codes G0551 and 99452 are reported by the psychologist or treating/requesting provider for the total time spent preparing records and the referral for the consulting clinician. This service is reported when it takes 16–30 minutes to prepare the referral and/or communicate with the consultant.

Another core component of the interprofessional consultation services is the acquisition of advance patient consent. The treating/requesting provider must obtain advanced consent from the patient prior to a psychologist providing consultative services, as it will require a separate copay. APA strongly recommends that psychologists always check the patient’s record to confirm consent has been obtained and documented prior to providing your expert advice.

APA is dedicated to improving population health, along with advocating for financial incentives that support psychologists’ involvement in these efforts. A population health approach, or preventive health approach, focuses on improving the health, health equity, safety, and well-being of entire populations, including individuals within those populations. Providing interprofessional consultation services is an important part of addressing population health as well as increased integration of mental and behavioral health services in interdisciplinary settings. Further, interprofessional consultation services have the potential to enhance quality and coordination of care and address persistent workforce shortages that are impacting patient access to medically necessary mental health treatment.

Case 1

A primary care physician (PCP) consults a psychologist by telephone conversation. The PCP states that consultative services are needed for a 20-year-old Latinx female patient who presents with flat affect, weight gain, and significant fatigue. The patient reports that she has been staying up until 3 or 4 a.m. and sleeping all day. She failed two of her classes and will have to attend summer school to make up the credits. Her PHQ-9A is elevated (14) and she reports having thoughts of harming herself on item 9.

The psychologist consultant reviews the case and verbally provides the PCP with assessment and management recommendations which include the need to complete a risk assessment and safety plan prior to leaving the clinic, a plan to conduct ongoing safety checks, and referral to a community therapist. Also, recommendations on sleep hygiene, behavioral activation, and lifestyle issues related to weight management. The psychologist then writes up the assessment and management recommendations and transmits the report to the treating/requesting provider for inclusion in the patient medical record.

Billing: Report one unit of code G0549 or 99449, indicating the psychologist spent a total of 35 minutes of consultative services, including 20 minutes of verbal discussion with the patient’s treating provider, and 15 additional minutes reviewing the patient’s medical record, doing research review, creating and sending the written report of findings, and expert advice.

Case 2

A pediatrician consults a psychologist electronically through the EHR. The pediatrician states reason for consult: “Patient is 4-year-old child with speech delay that is exhibiting impulsive behaviors that include tantrums and aggression towards siblings. Pediatrician indicates they are looking for guidance on typical development, differentiating ADHD from other disruptive behavior problems, and possible nonmedication treatment options.”

The psychologist consultant reviews the case and provides assessment and management recommendations which includes information regarding differential diagnosis of ADHD or disruptive behavior disorders, including discussion of diagnostic criteria and patient’s symptom presentation. Psychologist consultant recommends evidence-based behavioral therapy interventions for disruptive behavior, particularly those emphasizing the increase in positive attachment/warmth and decreasing harsh/coercive parenting.

Time: 16 minutes total time. (10 minutes of responding to the patient’s treating provider via EHR about the case and giving recommendations and 6 additional minutes of chart review and documentation).

Billing: Report one unit of code G0549 or 99451, indicating the psychologist spent a total of 16 minutes: 5 minutes performing consultative services, and 10 minutes responding to the patient’s treating provider via EHR about the case and creating and sending the written report of recommendations to treating provider (all communication was electronic).

Interprofessional consultations are time-based services; therefore, psychologists are required to document the start and stop times and/or total time spent providing consultation services. When reporting consultation services that require both a verbal and written report (codes G0546–G0549, 99446–99449), code selection is based on cumulative, even if that time occurs on multiple days.

Consultant communications with the patient and/or family may be reported using 98966, 98967, 98968, 99421, 99422, 99423, and the time related to these services is not used in reporting 99446, 99447, 99448, 99449.

• Do not report codes G0546, G0547, G0548, G0549, G0550, G0551, 99446, 99447, 99448, 99449, 99451, or 99452 more than once for the same patient in a 7-day period.
• Do not report G0546, G0547,G0548, G0549, 99446, 99447, 99448, or 99449, if greater than 50% of time is spent in data review and/or analysis, do not bill those codes.
• Do not bill G0550 of 99451 for services that last less than 5 minutes of consultative service.

Treating providers can request the opinion and/or treatment advice of a physician or other QHP, such as a psychologist, that has specific specialty expertise, to assist in diagnosis and/or management of the patient’s problem, without the consulting provider ever seeing the patient.

When consultative services are requested, the patient can be a new or an established patient to the consultant, and the condition for which the consultation is being requested can be a new or existing problem.

Proper reporting of interprofessional consultation services can occur as long as:

• The psychologist consultant has not had a face-to-face visit with the patient within the last 14 days, and/or
• The consultation services provided by the psychologist does not result in a face-to-face service with the patient within the next 14 days.

The following are examples of situations where it would not be appropriate to report interprofessional consultation services:

• If an in-person visit with the psychologist consultant has occurred within the previous 14 days or will occur within the next 14 days.
• If the sole purpose of the communication with a treating provider is to arrange transfer of care or an in-person consultation with the psychologist consultant.

Additionally, interprofessional consultation services cannot be reported more than once, for the same patient, in a 7-day period.

The following are required items to be documented in the patient medical record when these services are provided:

• Verbal consent was obtained by the treating/requesting provider for the interprofessional consultation from the patient/family.
• The treating/requesting provider’s written or verbal request, as well as the reason the request was made, for the consult.
• The amount of time spent providing the interprofessional consultation services, and should be reported based on cumulative time spent, even if that time occurs on subsequent days.

APA recommends that, in order to reduce the risk of your claim(s) being denied for reporting noncovered/noncontracted codes, you should check each payer policy, as well as the list of codes included in your contract with each payer, to determine which codes are covered/reimbursed. Additionally, please refer to APA’s Payers Guide: Utilizing Interprofessional Telephone/Internet/Electronic Health Record Consultations CPT^® Codes for Psychologists for further information on advocating for coverage of these services.

National Correct Coding Initiative (NCCI) has specifically indicated that you cannot provide psychotherapy services and interprofessional consultation services, for the same patient, on the same date of service.

It is important to note however, that while specific NCCI edits do not exist for code(s)/service(s) typically provided and reported by psychologists, the psychologist consultant cannot report interprofessional consultation services if:

• they had a face-to-face visit with the patient within the last 14 days, and/or
• the consultation services provided by the psychologist results in a face-to-face visit with the patient within the next 14 days.

Currently (as of the posting of Practitioner to Practitioner Edits effective July 1, 2025), no NCCI edits exist when billing psychotherapy services (90791-90837) in conjunction with G0546–G0551.

Psychologists should bill interprofessional consultation services based on whether the consult was with or without discussion and the time spent providing the consultation.

If the consult was with discussion, the psychologist will bill codes 99446–99449, based on the total/cumulative time devoted to performing the service. Code selection is then based on the specified time frames stated in the CPT code descriptors (99446: 5–10 minutes, 99447: 11–20 minutes, 99448: 21–30 minutes, and 99449: 31+ minutes).

If the consult was without discussion and greater than 5 minutes, 99451 is billed.

The patient for whom the interprofessional telephone/internet/electronic health record consultation is requested may be either a new patient to the consultant or an established patient with a new problem or an exacerbation of an existing problem. The consulting provider, however, cannot have a face-to-face encounter with the patient 14 days before or after offering treatment recommendations to the attending provider.